Radiology Coding Alert

Put your G2211 coding concerns on hold — for now.

The COVID-19 relief bill has been officially signed into law — and there’s a lot included in it that will impact your radiology practice. In fact, the formally titled Consolidated Appropriations Act (CCA), 2021 will end up undoing much of the information you just finished digesting within the Medicare Physician Fee Schedule (MPFS) 2021 Final Rule.

Two of the most important changes include a revision to the 2021 MPFS budget neutrality cuts and a moratorium on payment for a brand new HCPCS Level II evaluation and management (E/M) code.

Read on for a breakdown of some of what’s included in the relief bill and how it will impact your radiology practice’s bottom line.

Take a Rain Check on Your G2211 Coding Woes

Before getting to the good news involving physician reimbursement, you might be relieved to know that the CCA has placed a moratorium on payment for the newly introduced add-on code G2211 (Visit complexity inherent to evaluation and management associated with medical care services that serve as the continuing focal point for all needed health care services and/or with medical care services that are part of ongoing care related to a patient’s single, serious condition or a complex condition. (Add-on code, list separately in addition to office/outpatient evaluation and management visit, new or established)).

“Congress called for a three-year delay (until at least 2024) in prohibiting CMS from making payments for G2211 or any similar code,” says Linda Vargas, CPC, CPMA, CPCO, CPC-I, CEMC, CCC, CGSC, Coding Manager at Truman Medical Centers in Kansas City, Missouri. “As discussed in the relief bill, part of the justification for delaying G2211 is that it will actually help pay for a 3.75 percent increase to offset the previous conversion factor (CF) cut,” Vargas explains.

Physician practices that were scrambling to prepare for G2211 implementation are sure to breathe a sigh of relief knowing that G2211 will no longer influence their E/M coding for the 2021 calendar year (CY). That’s because the details surrounding G2211 in the 2021 MPFS final rule were murky at best.

In fact, CMS attempted to elaborate on the creation, use, and subsequent implementation of G2211 across nearly 12 pages within the final rule. However, coders were ultimately left with more questions than answers as they rushed to make the necessary preparations.

Get a Little Background on G2211

CMS introduced you to code G2211 in the final rule by stating: “the time, intensity, and physical effort (PE) involved in furnishing services to patients on an ongoing basis that result in a comprehensive, longitudinal, and continuous relationship with the patient and involves delivery of team-based care that is accessible, coordinated with other practitioners and providers, and integrated with the broader health care landscape, are not adequately described by the revised office/outpatient E/M visit code set.”

That’s where G2211 was supposed to come into play. The idea was that, for applicable E/M services, you would include code G2211 alongside the respective new or established patient office/outpatient visit code. While CMS uses plenty of words to convey their point, the general consensus was the final rule didn’t have much clarity surrounding the use of G2211. Fortunately, CMS has at least three more years to come up with further instruction on G2211 reporting.

Review Plan to Counteract MPFS Budget Neutrality Cuts

There’s more good news on the way for those practices that were bracing for a revenue hit following the Medicare payment reduction of 10.2 percent outlined in the MPFS 2021 final rule. As a means of providing relief to physicians during the public health emergency (PHE), the CCA includes the following:

• “In order to support physicians and other professionals in adjusting to changes in payment for physicians’ services during 2021, the Secretary shall increase fee schedules under sub section (b) that establish payment amounts for such services furnished on or after January 1, 2021, and before January 1, 2022, by 3.75 percent.”

CMS explains that it’s not only the 3.75 percent pay raise increase that will be influencing reimbursement in 2021. The three-year suspension of code G2211, which, according to CMS accounted for “about $3 billion — or 3 percent — of spending in the Medicare payment schedule,” helps to further reduce the planned budget neutrality decrease.

To consider: “Keep in mind that this is not a 3.75 percent increase over the 2020 conversion factor [CF],” says Barbara J. Cobuzzi, MBA, CPC, COC, CPC-P, CPC-I, CENTC, CPCO, of CRN Healthcare in Tinton Falls, New Jersey. “Rather, it’s a percent increase over the planned decrease of the CF of 10.2 percent as included in the 2021 MPFS Final Rule,” Cobuzzi explains.

While this is undoubtedly positive news for all radiological specialties, the combined impact of the fiscal changes still result in a loss in reimbursement on the year. Per the 2021 MPFS final rule, diagnostic radiology was expecting a combined -10 percent decrease in reimbursement. Factoring in the combined impact with the additional 3.75 percent conversion factor (CF) increase, diagnostic radiology should now expect a net -3 percent combined impact for 2021. Interventional radiology will shift from an expected -8 percent combined impact to -2 percent combined impact in 2021. Finally, nuclear medicine will shift from a -8 percent combined impact to a -1 percent combined impact.

You can read the entirety of what’s included in the CCA at https://rules.house.gov/sites/democrats.rules.house.gov/files/BILLS-116HR133SA-RCP-116-68.pdf.